BEFORE THE HEARING BOARD

OF THE

ILLINOIS ATTORNEY REGISTRATION

AND

DISCIPLINARY COMMISSION

In the Matter of:

JASON ROBERT CRADDOCK,

Attorney-Respondent,

No. 6242722.

Commission No. 2017PR00115

FILED --- December 1, 2017

COMPLAINT

Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney, Christopher Heredia, pursuant to Supreme Court Rule 753(b), complains of Respondent Jason Robert Craddock, who was licensed to practice law in Illinois on November 6, 1997, and alleges that Respondent has engaged in the following conduct which subjects Respondent to discipline pursuant to Supreme Court Rule 770:

ALLEGATION COMMON TO ALL COUNTS

1. At all times alleged in this complaint, Respondent owned and operated the Law Office of Jason R. Craddock ("Respondent's law firm"), and was the sole attorney operating and providing services as part of that entity.

COUNT I
(Conduct to embarrass and burden a third person in
the course of pending litigation - Courtney Lindbert
)

2. Beginning in 2014, and at all further times alleged in this count, Respondent represented Judith Wyman ("Wyman") and Kitty Knapp ("Knapp") in separate employment discrimination cases related to their employment termination from the Olympic Star Restaurant ("Olympic Star"), operated by Evgeros, Inc. ("Evgeros"). Respondent filed the following cases on behalf of each client in the United States District Court for the Northern District of Illinois: Judith Wyman v. Evgeros, Inc. d/b/a Olympic Star Restaurant ("Wyman matter"), case number 1:15-CV-02758, which was assigned to the Hon. Matthew F. Kennelly ("Judge Kennelly"); and Kitty Knapp v. Evgeros Inc., d/b/a Olympic Star Restaurant ("Knapp matter"), case number 1:15-CV-00754, which was assigned to the Hon. Gary Feinerman ("Judge Feinerman"). Attorney Courtney Lindbert ("Lindbert"), from the law firm of Andreou and Casson, Ltd. ("Andreou and Casson"), represented Evgeros in both matters.

3. On September 15, 2016, while both the Wyman and Knapp matters were pending, Respondent and Lindbert appeared before Judge Kennelly in relation to the Wyman matter for a hearing on the Court's rule to show cause entered on September 12, 2016. The Court had entered the rule to show cause based on Respondent's alleged failure to file a response to Lindbert's motion for summary judgment. Judge Kennelly concluded the hearing by allowing Respondent additional time to file the appropriate pleading.

4. Following that hearing, Respondent and Lindbert exited Judge Kennelly's courtroom, and had a conversation in a hallway outside the courtroom regarding the Wyman case and pleadings which Lindbert intended to file. During that conversation, outside the courtroom, Lindbert informed Respondent of her intention to file pleadings related to sanctions under Federal Rule of Civil Procedure 11. When Lindbert asked Respondent if Respondent heard her, Respondent stated "I did, Cunt-ney." Lindbert responded "Excuse me," to which Respondent again stated "I did, Cunt-ney."

5. On December 3, 2016, while both the Wyman and Knapp cases were pending, Respondent sent an email from his law firm email address to Lindbert at her law firm email address at approximately 10:46 p.m. regarding the parties' ongoing litigation. In his email, Respondent began his correspondence by addressing Lindbert as "Cuntney Lindbitch."

6. On December 5, 2016, attorney Luke Casson ("Casson"), a partner with Andreou and Casson, informed the Hon. Ruben Castillo, Chief Judge of the U.S. District Court of the Northern District of Illinois, of Respondent's conduct towards Lindbert, and requested that the Court taken action against Respondent.

7. On December 13, 2016, the Executive Committee of the U.S. District Court for the Northern District of Illinois issued a rule to show cause by way of a citation, ordering Respondent to show cause why he should not be disciplined for his conduct towards Lindbert, as reported by both Lindbert and Casson.

8. On January 18, 2017, following Respondent's citation response and the Executive Committee's review of the allegations and other information, the Executive Committee entered an order finding that Respondent engaged in the misconduct described in paragraphs 4 and 5. In imposing discipline on Respondent for his misconduct, the Executive Committee struck Respondent from the Trial Bar of the Northern District of Illinois and suspended him from the General Bar of the Northern District of Illinois for 12 months. The Order also required that, as part of any reinstatement petition, Respondent must demonstrate having sought professional assistance with both his compliance with the Rules of Professional Conduct as well as his anger management.

9. The statements Respondent made to Lindbert on September 15, 2016, referred to in paragraph 4, above, served no purpose other than to embarrass, intimidate, and burden Lindbert during the course of his representation of Wyman and Knapp. The email Respondent sent to Lindbert on December 3, 2016, referred to in paragraph 5, above, served no purpose other than to embarrass, intimidate, and burden Lindbert during the course of his representation of Wyman and Knapp.

10. By reason of the conduct described above, Respondent has engaged in the following misconduct:

  1. in representing clients in employment discrimination matters, using means that have no substantial purpose other than to embarrass, delay, or burden a third person, by conduct including addressing opposing counsel Courtney Lindbert as "Cunt-ney" following a court proceeding during discussions related to the pending Wyman litigation, and sending Lindbert an email related to the parties' ongoing litigation addressing Lindbert as "Cuntney Lindbitch," in violation of Rule 4.4(a) of the Illinois Rules of Professional Conduct (2010); and

  2. conduct that is prejudicial to the administration of justice by conduct including addressing opposing counsel Courtey Lindbert as "Cunt-ney" following a court proceeding during discussions related to the pending Wyman litigation, and sending Lindbert a harassing email to Lindbert's law firm email address related to the parties' ongoing litigation addressing Lindbert as "Cuntney Lindbitch," in violation of Rule 8.4(d) of the Illinois Rules of Professional Conduct (2010).

COUNT II
(Conduct to embarrass and burden a third person in
the course of pending litigation - Antoinette Granholm
)

11. Beginning in 2014, and at all further times alleged in this count, Respondent represented Sherri Klocek ("Klocek") in a domestic relations matter involving the dissolution of her marriage with her ex-husband, David Klocek ("David"). The case was docketed in the Circuit Court of Will County as David Klocek v. Sherri Klocek ("Klocek matter"), case number 14-D-02108, and assigned to the Hon. Victoria K. Kennison ("Judge Kennison"). Attorney Antoinette Granholm, from the law firm of O'Dekirk, Allred and Associates, LLC, represented David.

12. On January 21, 2016, case number 14-D-02108 was called for hearing before Judge Kennison. At that time, Respondent and Granholm appeared before Judge Kennison, and Granholm presented two emergency motions. Judge Kennison concluded the hearing by granting one of Granholm's motions and continuing case number 14-D-02108 for an additional status date.

13. Following that hearing, Respondent and Granholm exited Judge Kennison's courtroom, and had a conversation in the hallway regarding the Klocek matter and ongoing discovery sought by Granholm. During that same conversation, in response to Granholm's requests for discovery, Respondent asked Granholm why she had to "always be such a bitch."

14. Shortly after that conversation, Granholm reentered Judge Kennison's courtroom. As Granholm was again leaving the courtroom, Karen Humphries ("Humphries"), Respondent's paralegal, called Granholm a "bitch" as Granholm walked past Humphries on her way out of the courtroom.

15. Following being referred to as a "bitch" by both Respondent and Humphries, Granholm returned to Judge Kennison's courtroom to request that she and Respondent reappear to address the behavior and language of Respondent and Humphries. Judge Kennison granted Granholm's request, and Granholm informed Judge Kennison that both Respondent and Humphries referred to Granholm as a "bitch" in speaking to Granholm just minutes before.

16. Judge Kennison admonished Respondent about his language, and instructed Respondent to direct Humphries' to avoid engaging in the same behavior and language. Respondent acknowledged that he called Granholm a "bitch", and also acknowledged Humphries' language towards Granholm, but responded to Judge Kennison that his and Humphries' actions were the result of provocation by Granholm.

17. The statements Respondent made to Granholm on January 21, 2016, referred to in paragraph 13, above, served no purpose other than to embarrass, intimidate, and burden Granholm during the course of Respondent's representation of Klocek.

18. By reason of the conduct described above, Respondent has engaged in the following misconduct:

  1. in representing a client in a domestic relations matter, using means that have no substantial purpose other than to embarrass, delay, or burden a third person, by conduct including calling opposing counsel Antoinette Granholm a "bitch" during discussions related to discovery in the pending Klocek litigation following a court proceeding, in violation of Rule 4.4(a) of the Illinois Rules of Professional Conduct (2010); and

  2. conduct that is prejudicial to the administration of justice by conduct including calling opposing counsel Antoinette Granholm a "bitch" during discussions related to discovery in the pending Klocek litigation following a court proceeding, in violation of Rule 8.4(d) of the Illinois Rules of Professional Conduct (2010).

WHEREFORE, the Administrator requests that this matter be referred to a panel of the Hearing Board of the Commission, that a hearing be conducted, and that the Hearing Panel make findings of fact, conclusions of fact and law, and a recommendation for such discipline as is warranted.

Christopher Heredia
Counsel for Administrator
One Prudential Plaza
130 East Randolph Drive, Suite 1500
Chicago, Illinois 60601
Telephone: (312) 565-2600
Email: cheredia@iardc.org

Respectfully submitted,

Jerome Larkin, Administrator
Attorney Registration and
Disciplinary Commission

By:  Christopher Heredia